UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK JANE DOE 43 Plaintiff, v. JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROFF and Defendants. No. 17 Civ. 00616 (JGK) MEMORANDUM IN OPPOSITION TO LETTER MOTION TO OPPOSE ALTERNATIVE SERVICE ON MAXWELL Plaintiff, Jane Doe 43, by and through the undersigned counsel, now responds to the letter motion on behalf of non-party Haddon, Morgan and Foreman, P.C. ("Haddon Morgan") requesting that the Court withdraw its order permitting alternative service of defendant Ghislaine Maxwell or, in the alternative, requesting an opportunity to file objections to alternative service. DE 69. The Court properly allowed alternative service on Maxwell through the Haddon Morgan law firm, a law firm that remains in close contact with Maxwell and, indeed, was even representing Maxwell in a related case before this Court within the last week. The motion lacks any merit, and the Court should deny it. Procedural Background As the Court is aware from previous pleadings, this case involves allegations by Jane Doe 43 against powerful and wealthy defendants — including Ghislaine Maxwell — who are alleged to have been running an illegal international sex trafficking organization. For example, as alleged in the complaint, "Defendant Maxwell was for decades the highest-ranking employee of the EFTA00792797